Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Valuation - inclusion of portion of 50% of sales tax retained by the assessee in the value of excisable goods - since the balance of 50% of sales is neither payable nor paid, additions confirmed - SC
Valuation - inclusion of portion of 50% of sales tax retained by the assessee in the value of excisable goods - since the balance of 50% of sales is neither payable nor paid, additions confirmed - SC
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